UNIVERSITY OF HOUSTON SYSTEM
ADMINISTRATIVE MEMORANDUM
SECTION:
Information Technology
AREA:
Computing Services
SUBJECT:
Data Classification and Protection
1.
Number:
07.A.08
PURPOSE
The purpose of this policy is to direct information owners and information custodians in
the assessment of information and information systems to determine the appropriate data
classification level, which then prescribes the necessary security measures which must be
in place.
For guidelines related to the disclosure of information, refer to SAM 01.D.06, Protection
of Confidential Information and the Office of General Counsel.
2.
POLICY
It is the policy of the University of Houston System (UHS) to ensure data is appropriately
classified and technical and physical security safeguards are implemented to protect the
data. Appropriate protection measures must be applied to UHS information, no matter
the location where the information is stored or accessed.
3.
DEFINITIONS
3.1.
Critical information resource: An information resource housing confidential,
sensitive personal or mission critical information. Critical information resources
must have the following physical and technical safeguards implemented:
A.
Physical access granted only to authorized personnel via access cards,
keys or other control mechanisms.
B.
Protection from environmental hazards.
C.
Regularly completed backups of all files. If the component campus
backup system is not used, the backup data must be stored in a separate,
secure area.
D.
Uninterrupted power supply (UPS).
E.
Relevant security patches installed.
F.
Anti-virus software installed and appropriately configured.
G.
Unnecessary and/or inactive accounts must be disabled or deleted.
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AM No. 07.A.08
4.
H.
Vendor-supplied system passwords must be replaced with strong
passwords.
I.
Audit/security logs enabled on the critical information resource.
J.
Prior to the disposal of the critical information resource, a secure
destruction method must be used to ensure the resource is sanitized
rendering the data unrecoverable.
3.2.
Information Custodian: An information custodian is a person (or department)
providing operational support for an information resource (e.g., server
administrators).
3.3.
Information Owner: An information owner is the person responsible for the
business use of a collection of information or the business function supported by a
system (e.g., the Registrar is the information owner of student records). The
information owner may also be responsible for other information resources
including personnel, equipment, and information technology that support their
business function. The head of a respective college, division or department may
be the information owner, and ownership may be shared by managers of different
departments.
3.4.
Information resource: Procedures, equipment, and software that are employed,
designed, built, operated, and maintained to collect, record, process, store,
retrieve, display, and transmit information.
DATA DEFINITIONS
4.1
Confidential information (Level 1 data): Information, as defined by
SAM 01.D.06 – Protection of Confidential Information, that includes, but is not
limited to, social security numbers, educational records as defined by the Family
Educational Rights and Privacy Act (“FERPA”), health care information as
defined by the Health Insurance Portability and Accountability Act (“HIPAA”)
and other applicable law, and customer information as defined by the GrammLeach-Bliley Act (“GLB Act”).
4.2
Sensitive personal information (Level 1 data): As defined by the
Texas Business and Commerce Code Section 521.002(a)2),
A.
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an individual’s first name or first initial and last name in combination with
any one or more of the following items, if the name and the items are not
encrypted:

social security number;

driver’s license number or government-issued identification
number; or
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AM No. 07.A.08

B.
5.
account number or credit or debit card number in combination with
any required security code, access code, or password that would
permit access to an individual’s financial account.
Information that identifies an individual and related to:

The physical or mental health or condition of the individual;

The provision of health care of the individual; or

Payment for the provision of health care to the individual.
4.3
Mission-critical information (Level 1 data): Information defined by the university
or information owner to be essential to the continued performance of the mission
of the University or department. An event causing the unavailability of missioncritical information would result in consequences such as significant financial
loss, institutional embarrassment, failure to comply with regulations or legal
obligations, or closure of the University or department.
4.4
Protected information (Level 2 data): Information that may be subject to
disclosure or release under the Texas Public Information Act as requested.
4.5
Public information (Level 3 data): Information readily available in the public
domain, such as information posted on the component university’s public web
site, and any other information not classified as Level 1 or 2.
CLASSIFYING DATA
5.1
It is the responsibility of the information owner to classify information for which
they are responsible into one of the types listed in Section 4.
5.2
It is the responsibility of the information custodian to ensure the appropriate
technical and physical security safeguards are implemented as directed by the
information owner.
5.3
If the information owner cannot classify data based on the definitions in
Section 4, the data should be classified according to the requirements of
confidentiality, integrity, or availability of the information. These requirements
may be defined by documents such as non-disclosure agreements, memoranda of
understanding, service level agreements, etc. Data must be classified by the
highest level identified for any one of the criteria.

Confidentiality − Data must be limited to individuals with sufficient
privileges and demonstrated need.

Integrity − Data must be whole, complete, and uncorrupted.

Availability − Data must be able to be accessed in a timely manner and
usable format.
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Information Protection Level
Criteria
6.
Required
Recommended
Optional
Confidentiality Level 1
Level 2
Level 3
Integrity
Level 1
Level 2
Level 3
Availability
Level 1
Level 2
Level 3
DATA PROTECTION REQUIREMENTS
6.1
6.2
6.3
Level 1 − Data classified as Level 1 must be protected in the following manner:
A.
Must be stored on a critical information resource.
B.
Must have appropriate data access controls in place.

If electronic information, access must be granted only through the
use of a user ID and complex password.

If hard copy information, must be stored in a locked location (such
as a locked file cabinet).
C.
Must not be transmitted via wireless network devices unless encrypted.
D.
Must not be transmitted by e-mail unless encrypted.
E.
Should not be stored on a removable or portable device (such as a flash
drive or laptop). If a valid business need requires level 1 data to be stored
on a removable or portable device, the information must be encrypted.
F.
Should not be stored on non-university devices. If a valid business need
requires level 1 data to be stored on a non-university device, specific
permission must be obtained in advance from the department head or
component university Security Officer.
Level 2 − Data classified as Level 2 does not require specific protection measures,
but the following safeguards are recommended to ensure the confidentiality,
integrity, and availability of the information.
A.
Should be stored on a critical information resource.
B.
Should have appropriate access controls in place (e.g., user ID and
password).
Level 3 − Data classified as Level 3 has no requirement for confidentiality,
integrity, or availability. As such, no specific protection measures are required.
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7.
8.
REVIEW AND RESPONSIBILITIES:
Responsible Party:
Associate Vice Chancellor for Information Technology
Review:
Every three years on or before June 1
APPROVAL
Approved:
Jim McShan
Interim Vice Chancellor for Administration and Finance
Renu Khator
Chancellor
Date:
June 12, 2015
REVISION LOG
Revision
Number
Approved
Date
1
09/06/2011
Initial version (MAPP 10.05.03)
2
06/12/2015
Converted from MAPP 10.05.03 to SAM 07.A.08
June 12, 2015
Description of Changes
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